Popular parlance test governs exemption classification: toffee was not treated as sweetmeat, so tax exemption remained available.

Exclusionary entries in a sales tax exemption notification must be construed strictly in light of the notification's object, which was to promote industrial development by exempting eligible new, expanded, diversified or modernised units. The words "commodities of like nature" extend only to similar items and do not enlarge the meaning of "sweetmeat" itself. Classification must be determined by popular parlance in the relevant local market, not by a wide dictionary meaning or foreign understanding. On that test, toffee was not shown to be understood in Uttar Pradesh as mithai or sweetmeat, so manufacturing units producing toffees remained entitled to exemption.

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Issues: Whether toffee falls within the expression "sweetmeat" or "commodities of like nature" in the exclusionary entry of the sales tax exemption notification issued under Section 4A of the Uttar Pradesh Sales Tax Act, 1948, so as to disentitle the industrial units manufacturing toffees from eligibility for exemption.

Analysis: The notification was intended to promote industrial development by granting exemption to new units and units undertaking expansion, diversification or modernization, while excluding specified industries. The expression in the exclusionary list had to be construed in the context of that object and not by giving an artificially wide dictionary meaning to the word "sweetmeat". The words "commodities of like nature" expanded the exclusion only to similar commodities and did not enlarge the meaning of "sweetmeat" itself. The correct approach was the popular parlance test, namely, how the commodity is understood in India and in the relevant State, and not how it may be understood in the country of origin. On that test, toffee was not shown to be understood as mithai or sweetmeat by dealers or consumers in Uttar Pradesh.

Conclusion: Toffee is not covered by the words "sweetmeat" or "commodities of like nature" in the notification, and the industrial units manufacturing toffees were entitled to the exemption benefit.

Ratio Decidendi: Exclusionary entries in an exemption notification must be construed strictly in light of the object of the notification, and a commodity must be classified according to its popular meaning in the relevant local market rather than by a wide dictionary meaning or foreign understanding.

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